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  #81  
Old 23.07.2012, 20:23
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Re: $21Trillion: hoard hidden from taxman by global elite

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But the premium profits rarely go to the companies home or where the technology was developed, do they?
They do, actually.

Well, at least, making sure that they do (i.e. advising for positions that are both legal and sustainable/defensible) is my job

EDIT: great thread/debate, by the way. Thanks BrianJW and all others (OP in primis)

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  #82  
Old 23.07.2012, 20:39
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They do, actually.

Well, at least, making sure that they do (i.e. advising for positions that are both legal and sustainable/defensible) is my job

EDIT: great thread/debate, by the way. Thanks BrianJW and all others (OP in primis)
Well where the risk of that development was bourne, in any case. C.f. contract R&D.
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  #83  
Old 23.07.2012, 20:55
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Re: $21Trillion: hoard hidden from taxman by global elite

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They do, actually.

Well, at least, making sure that they do (i.e. advising for positions that are both legal and sustainable/defensible) is my job

EDIT: great thread/debate, by the way. Thanks BrianJW and all others (OP in primis)
Yes its not cut and dry international tax law. I bags not doing Fatmanfilms tax return ;-).

But my experience has seen the risk bourne by the shareholder (in the olden days of in-house R&D) and the profits moved from the country of sale to a low tax domicile which had nothing to do with the development or risk involved in the product. The problem then became you couldn't take the cash home to the shareholders so you ended up with large offshore cash holdings.

Ive also seen just paper invoices moving profits here where our Swiss sister company did very little more than collecting cash. All legal and justified/ defendable.

I haven't designed these systems myself but have been close enough to building audit defence documentation in more than one organization.

I just wish I was hiding my 21 trillion from someone ;-)
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  #84  
Old 23.07.2012, 21:11
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Re: $21Trillion: hoard hidden from taxman by global elite

My dearly departed gran used to enjoy quoting..

"in this world nothing can be said to be certain, except death and taxes."

Turns out she's definitely right about one of them.
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  #85  
Old 23.07.2012, 21:49
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Re: $21Trillion: hoard hidden from taxman by global elite

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Consider these questions: who invested in building the mine, who bears the cost of ongoing maintenance and upgrades, bears the risk underlying product/market fluctuations, bears the risk underlying material defects, carries out the negotiations with customers and suppliers, deals with process design and improvement, who takes the brunt if business is wrong? From a commercial perspective, where the wealth is generated, and where the entrepreneurial risk is borne, there should be the profit.

The fact that a nation remains poor is indeed a bad thing, but do we really want to lay the blame on the company? On what basis? On the fact that they reap the profits for which they bore the risk?
sure they can reap the profits but the profits were made in Africa and should be taxed in Africa. Not shifted through supply chain manipulations to a Tax Haven.

Also, the revenues made from mining are an example of what economists call a Rent income or benefit. The income generated has VERY little to do with the talent a company brings to the table and its resources and has almost EVERYTHING to do with the resources owned by a nation state.

To explain Rents i willl use this quick illustration. Say there was a busker, he has a choice, he could play on Bahnhofstrasse (provided ZH let him) or he could play in some village on the outskirts of Zurich. Why does he choose to play in one place over the other? The access to those willing to give him money. The more people in a location the more money he earns. Which is independent of his ability to play an instrument. So the monies he earns actually has little to do with his talent and more to do with the resources he is exploiting.

Mining is considered by economists as another prominent example!
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  #86  
Old 23.07.2012, 21:57
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Re: $21Trillion: hoard hidden from taxman by global elite

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I just wish I was hiding my 21 trillion from someone ;-)
Sure you would wish that? Imagine how much effort it would take to hide this much money.
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  #87  
Old 23.07.2012, 22:15
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Re: $21Trillion: hoard hidden from taxman by global elite

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.

Ive also seen just paper invoices moving profits here where our Swiss sister company did very little more than collecting cash. All legal and justified/ defendable.

I haven't designed these systems myself but have been close enough to building audit defence documentation in more than one organization.
and here lies the problem. it is this money that organisations like the Tax Justice Network, the publishers of this study and some "leftist" politicians are trying to chase down.

What i dont understand is why so many effected jurisdictions are so soft about it. It probably also explains why certain extreme left run countries habitually forcefully take over sections of their economy. Like mineral extraction in Venezeula. Also why the Chinese hang onto their state owned models of company ownership.
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  #88  
Old 23.07.2012, 22:20
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Re: $21Trillion: hoard hidden from taxman by global elite

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sure they can reap the profits but the profits were made in Africa and should be taxed in Africa. Not shifted through supply chain manipulations to a Tax Haven.

Also, the revenues made from mining are an example of what economists call a Rent income or benefit. The income generated has VERY little to do with the talent a company brings to the table and its resources and has almost EVERYTHING to do with the resources owned by a nation state.

To explain Rents i willl use this quick illustration. Say there was a busker, he has a choice, he could play on Bahnhofstrasse (provided ZH let him) or he could play in some village on the outskirts of Zurich. Why does he choose to play in one place over the other? The access to those willing to give him money. The more people in a location the more money he earns. Which is independent of his ability to play an instrument. So the monies he earns actually has little to do with his talent and more to do with the resources he is exploiting.

Mining is considered by economists as another prominent example!

so there is a miner working 15 hours a day in bad conditions in africa.

then there is a multinational company based in switzerland who paid a gazillion dollars to the african government for the rights to mine there and funding the machinery, surveying etc.

where should the profits go? to the miner in the mine? or the company?
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  #89  
Old 23.07.2012, 22:20
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Re: $21Trillion: hoard hidden from taxman by global elite

Get yoursel' a cup of tea. This response will go on a bit.

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... companies are not charities: their goal is to create value for their shareholders, punkt.
Your assumption that value is purely monetary is curious and depressingly common. At the current rate, there'll be nothing left to exploit.

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What a load of populistic bollocks, excuse me.
What? You're not the 99.991%?

Why are you not on a yacht somewhere reading Puschkin?

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Using big headlines to impress discontented people to cover up for politicians' sc*ew ups!
Careful; the "discontented" are the 99.991%. Imperfect though Democracy is, it's still the least worst option and in principle the will of the people.

A lot more discontent is beginning to be focused on repugnant, aggressive tax dodgers who focus on technicalities and ignore the greater good. More on this theme later. I hope you have cookies with that tea.

So:
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... company A used all available LEGAL means, as described in the current and effective tax law, to optimize their taxes, can someone please explain to me why they should be named and shamed? For what, for following the tax law???
By all means live long and prosper under the letters of the law but don't forget the Human element. (I have a great admiration for Technocrats abilities, even if their justifications are black and white.)


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Thank God there are countries like Switzerland that consider taxation as morally neutral!
Just remember this when the envelope is passed around the office for someone's birthday present. "I don't want to contribute and you can't make me feel bad". You'll be a little less popular with every birthday, but you'll at least have Donald Trump to look up to.

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The day I see the tax returns of these politicians...
Ah, everybody else is doing it so moral responsibility is null and void?

I doubt anyone here cares about the Politicos and their need for a hug. Why is the discussion consistently painted in a negative voice? Who cares about others; it's our own responsibilities we ought to consider.


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I would be curious to see how many of the people who posted here would voluntarily increase their tax burden "for the benefit of society". Or is it just the big bad multinational companies who should do that? I am happy to pay what I owe, not more not less, support the causes that I deem worthy without being forced, and that's it. As I said, if you are a good soul, run a charity, not a corporation.
A well run system enjoys the division of labour, ideally doing away with the need for charity. That charity is necessary ought to indicate things are wonky in OUR society. Politicians can only work with what they have despite their imperfections.

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Why fret about the situation? Greed, hoarding and exploitation are natural human traits. For some it equates to luxury, for most, wielding their power. Money is an enabler, nothing more...

...You get dealt your cards and then make do with what you have or trade up/down accordingly.
Welcome to the jungle, but you forgot about Mrs Miggins in her nursing home who through no fault of her own is on the pointy end of spending cuts. I could drone on about Bank bailouts and subsequent yadda but this reply is already epic. And I'm stone cold sober

I'm all for independence but we rely on each other. Adam Smith and his pins had something to say on the matter. Karl Popper et al went on with the Baton.

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It is a race to the bottom, and I'd argue that zero taxes is a good thing to aim for.
Best secure a source of water, some goats and plenty of ammo. Or jump to Saudi. They decapitate! With swords! It's cool.

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I love it how tax policy discussion brings out the closet Anarchists. no tax = no government = no society = anarchy.

Let us try it out :-P
Perhaps the resources our society provides are yet to be noticed or needed, let alone valued. Attitudes will change should a fall occur.

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Precisely. The more big business and the super rich can hide their assets the more pain the rest of society feels.
Yet the enablers will have us know it's not their fault. The law allows it!

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It actually means the rich have more money to spend in the economy, not necessarily a bad thing.
There's little evidence for the trickle down effect. It doesn't exist.

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... If we go by strict economic theory...
But the world is more complex than black or white.

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The answer is: the one that offers the best conditions, and I am not talking only about tax rates - access to capital, educated workforce, intellectual property protection to cite only a few.
Well, I'm alright, Jack. I live in Switzerland. Bugger those places where the money's coming from. They can shrivel!

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You all talk about shifting corporate profits as if it's the simplest thing in the world - it's not that simple.
That's why they employ the Enablers. Whose talents may also be valuable in contributing to society, but there's a reason they're paid so well.

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What I am trying to say is that the reality is not that easy as populist politicians would have us believe...
We know the reality. People are not happy with the reality. Except the FatCats.

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From a commercial perspective, where the wealth is generated, and where the entrepreneurial risk is borne, there should be the profit.

The fact that a nation remains poor is indeed a bad thing, but do we really want to lay the blame on the company? On what basis? On the fact that they reap the profits for which they bore the risk?

We go back to the argument "running a business" vs "running a charity".
Nobody is against profit - we all need profit - but at what cost?

Here's a case study: Shell Oil and the Niger Delta. Good men were executed on fabricated charges because it suited the corrupt officials and Shell Oil's Shareholders. If we continue to ignore the moral responsibilities of our individual actions, we all have blood on our hands can consider ourselves enablers.

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Sure, then they get the routine return that a comparable independent party would earn by providing sales support/market development services. They DO NOT get the premium profits associated with the technology and the entrepreneurial risk.

This, by the way (alignment with the behavior that independent parties would engage in), is one of the core principles of transfer pricing. But you don't read that in the papers.
No, 'cause it's dull and deals with middlemen transactions as a consequence of a greater picture which is a bit Back Office in glamour.

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They do, actually.

Well, at least, making sure that they do (i.e. advising for positions that are both legal and sustainable/defensible) is my job

EDIT: great thread/debate, by the way. Thanks BrianJW and all others (OP in primis)
Sustainable / defensible used in a purely Next Quarter Report kinda way or ...like ...another way?


Kettle on, I need a cuppa myself now...

Hope you're all still alive. Peace 'n' love.



EDIT: Ah crap. The quoted Poster most mentioned went and edited their post. Sigh. Going to bed.
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Last edited by Uncle Max; 23.07.2012 at 23:23.
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  #90  
Old 23.07.2012, 22:25
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Re: $21Trillion: hoard hidden from taxman by global elite

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With the Swiss government printing approx 40,000 CHF PER DAY PER RESIDENT, there seems very little point in collecting taxes at all. Why not just print the money required, everybodies money is then devalued at the same rate, seems fair & no possibility to evade!
That is a really interesting point of view.
I never looked at it that way.
In theory, it makes sense.
Unfortunately, inflation is a cruel way to dispossess the middle-class.
Witnessed in the early 20s of last century's Germany and now witnessed again in Southern Europe.
Nothing good came out of it.
I think I read a statistics that the average real income of an American household has also basically been stagnating for the last thirty, forty years (often disguised by the fact that instead of one earner, there are 1.5 or 2 earners in a household).
Makes you wonder how long all that can go on.
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Old 23.07.2012, 23:31
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Re: $21Trillion: hoard hidden from taxman by global elite

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That is a really interesting point of view.
I never looked at it that way.
In theory, it makes sense.
Unfortunately, inflation is a cruel way to dispossess the middle-class.
Witnessed in the early 20s of last century's Germany and now witnessed again in Southern Europe.
Nothing good came out of it.
I think I read a statistics that the average real income of an American household has also basically been stagnating for the last thirty, forty years (often disguised by the fact that instead of one earner, there are 1.5 or 2 earners in a household).
Makes you wonder how long all that can go on.
Or for a quicker dispossession of the middle, upper, and lower class look at Zimbabwe. Its an extreme case of what inflation can do.
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  #92  
Old 24.07.2012, 00:22
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Re: $21Trillion: hoard hidden from taxman by global elite

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Sure you would wish that? Imagine how much effort it would take to hide this much money.

just spend it! :P
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  #93  
Old 24.07.2012, 06:17
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Re: $21Trillion: hoard hidden from taxman by global elite

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Also, the revenues made from mining are an example of what economists call a Rent income or benefit. The income generated has VERY little to do with the talent a company brings to the table and its resources and has almost EVERYTHING to do with the resources owned by a nation state.

To explain Rents i willl use this quick illustration. Say there was a busker, he has a choice, he could play on Bahnhofstrasse (provided ZH let him) or he could play in some village on the outskirts of Zurich. Why does he choose to play in one place over the other? The access to those willing to give him money. The more people in a location the more money he earns. Which is independent of his ability to play an instrument. So the monies he earns actually has little to do with his talent and more to do with the resources he is exploiting.

Mining is considered by economists as another prominent example!
Nice theory, but unfortunately in many cases wrong. There is a reason why foreign investors are called in even in countries with state owned mines, as even after decades of experience they lack the know-how to effectively extract the minerals in question and require superior technology. That is the reason why in almost any country MNCs are brought in. And mostly the only reason why little value remains in the country is because of corrupt local leaders, not because of unfavourable contract terms as some leftists often infer. But what's true of course is that the more isolated a regime is the more likely it will have little choice with which foreign investors to deal with, China certainly doesn't mind having no Western competitors.

So in short, there is heavy competition in getting mining licenses and contracts with SOEs (state owned enterprises), the countries are not being ripped off, it's their politicians that don't put it to proper use, just look at Luanda as a prime example.
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Old 24.07.2012, 07:19
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Re: $21Trillion: hoard hidden from taxman by global elite

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I'm less worried about companies that avoid tax, than wasteful governments that take tax and spend it on their own lavish benefits or on their favoured lobbyists.
I am far from believing that governments are perfect and ideal... but on average have the politicians I met wasted far less tax money/ resources that those oh-so-well-educated top level managers. Not because politicians are the better humans with a greater moral compass but because most western governments have some sort of checks in place. In the corporate world would that be the board... which is usually conveniently staffed with the pals of the CEO who then in turn give him a seat in their boards...

I know it seems the standard story Americans and Brits are taught in the media that only a free market can save the world... but I really do not know how many examples of failed banks we need to see: Just because somebody is not a politician does not mean he is not greedy and knows how to deal with money. And the best part is when these gentlemen at the end ask for a bail out cause they feel "too big to fail". Pumping tax money into certain banks was globally the biggest wasting of tax money...

A lot of things are wrong and out of proportion in our current world. I personally find the private sector on average worse than governments. The financial industry being typically on top of that list... from gambling investment banker all the way to private banker helping clients to dodge their taxes.

P.S: When companies "save" taxes abroad do they in practices cut the benefits of their employees - the people who work for them do simply not receive the streets, schools, hospitals and other public infrastructure they deserve based on their productivity. All in order to get the top ten managers an even bigger bonus.
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Old 24.07.2012, 09:07
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Re: $21Trillion: hoard hidden from taxman by global elite

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Nice theory, but unfortunately in many cases wrong. There is a reason why foreign investors are called in even in countries with state owned mines, as even after decades of experience they lack the know-how to effectively extract the minerals in question and require superior technology. That is the reason why in almost any country MNCs are brought in. And mostly the only reason why little value remains in the country is because of corrupt local leaders, not because of unfavourable contract terms as some leftists often infer. But what's true of course is that the more isolated a regime is the more likely it will have little choice with which foreign investors to deal with, China certainly doesn't mind having no Western competitors.

So in short, there is heavy competition in getting mining licenses and contracts with SOEs (state owned enterprises), the countries are not being ripped off, it's their politicians that don't put it to proper use, just look at Luanda as a prime example.
plus countries can tax a such activities at very high rates. i recall one oil company paying an effective 95% tax rate on oil extraction activities.
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Old 24.07.2012, 09:11
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Re: $21Trillion: hoard hidden from taxman by global elite

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I am far from believing that governments are perfect and ideal... but on average have the politicians I met wasted far less tax money/ resources that those oh-so-well-educated top level managers.
i disagree, i think the politicians have wasted the most money. i don't really care how much money a private person, or private company wastes as it is their money to waste.

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Pumping tax money into certain banks was globally the biggest wasting of tax money...
i agree, and guess who decided to do that? the politicians.

ireland was particularly scandalous since they had no need to bail out foreign creditors, but the politicians decided to put the entire population under effective debt slavery to help out foreign banks.
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Old 24.07.2012, 09:26
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Re: $21Trillion: hoard hidden from taxman by global elite

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I know it seems the standard story Americans and Brits are taught in the media that only a free market can save the world... but I really do not know how many examples of failed banks we need to see
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I know it seems the standard story Europeans are taught in school that only a strong government can save the world... but I really do not know how many examples of corrupt politicians we need to see
See what I did there? ;-) People are people, whether they're in government or corporations. Certain types of people, however, will naturally gravitate towards positions of power and attempt to increase that power. Whether it's the Head of HR or the tax man, we need to be very careful about letting them do so.
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Old 24.07.2012, 09:37
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Re: $21Trillion: hoard hidden from taxman by global elite

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See what I did there? ;-) People are people, whether they're in government or corporations. Certain types of people, however, will naturally gravitate towards positions of power and attempt to increase that power. Whether it's the Head of HR or the tax man, we need to be very careful about letting them do so.
Only difference being that you can influence one, while the other will simply go to a place with less "difficult" laws...
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Old 24.07.2012, 09:39
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Re: $21Trillion: hoard hidden from taxman by global elite

Thanks for the reply - got myself a cuppa last night, but Hemingway got the best of my attention, and so I postponed the reply

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What? You're not the 99.991%?
Why are you not on a yacht somewhere reading Puschkin?
I get sea-sick, so no

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By all means live long and prosper under the letters of the law but don't forget the Human element. (I have a great admiration for Technocrats abilities, even if their justifications are black and white.)
Not all is black and white, I agree, and for this I despise the witch hunt that is described in the article. We're gonna go on a crusade against these bad, bad guys to appease the people for our own shortcomings as politicians!

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Ah, everybody else is doing it so moral responsibility is null and void?
...
Sustainable / defensible used in a purely Next Quarter Report kinda way or ...like ...another way?
Moral responsibility is on top of the list. There is a lot of dirt in the industry, as with in any industry, but again, the witch hunting approach won't help the case. I cannot speak for all professionals in all branches of the field, but I can speak for myself - I work with integrity, and I can proudly say that out loud.

Concretely, this means a) I won't tell the client what he wants to hear, but what it is good for them, which may or may not coincide; b) I can put my foot down and say NO - no to a client, no to a project, no to a particular advice; and c) I firmly believe that it is our moral responsibility to promote, through our advice, cleaner practices and straightforward records in the industry. It is also our responsibility as professionals to show what exactly we do in a transparent way - there are publications, there are conferences, there are expert panels, there is knowledge sharing worldwide. I wish there was more non technical literature out there, like a "tax restructuring for dummies" so that people would hear the other side also and not just rely on these sensationalistic headlines.

However, I do not believe that we can't optimize the situation of a particular company working within the realm of legislations available. If the laws and the options are there, I am taking them. If I was a serious politician and I was unhappy with the current legislation, I would try to sit together with major corporate players, tax experts, lawyers, economists, the OECD, and so forth, to figure out ways to better address what makes me unhappy and find a common goal. You may or may not know, but the United Nations have begun to do a lot of work in this sense - question is: would the (corrupt) local politicians who pocket the money agree on setting some standards?

I have no, I repeat NO trust in politicians. In the virtual reality in my head, the perfect world would be governed by economists. But that's only in my head, obviously

With regards to defensibility, I mean when the tax authorities of the 50+ countries where company X is present come knocking at their door, they can show that they are following an economically rational behavior which complies with the law.

With regards to sustainability, I mean that the proposed model feeds from and enhances the business dynamics of company X, and is flexible enough to allow for growth and expansion in a varying environment.

Happy again?

EDIT: if you were referring to me, I only edited the last post to add the "EDIT: thanks for the discussion" blurb. The rest was and still remains as I originally wrote it.
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Old 24.07.2012, 09:50
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Re: $21Trillion: hoard hidden from taxman by global elite

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sure if the money is spent in the economy in which it is generated
I suppose that's down to the individual as they're earning the money I spend 50% back home and 50% here
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